The Substituted Heirs of Manuel Cabuenas v. Felisa Codilla Vda. de Ardiente

Summary

This Supreme Court case involved a property dispute over a 5.27-hectare lot in Cebu City between the heirs of Manuel Cabuenas/Agapito Cinco and Felisa Ardiente's family. The central issue was whether a 1962 deed of sale was valid or should be treated as a mortgage. Felisa, who was illiterate, claimed she believed the English-language document was only a mortgage, not a sale. The RTC initially upheld the deed's validity, but the Court of Appeals reversed, finding the contract voidable due to vitiated consent under Article 1332 of the Civil Code, which protects illiterate parties when contract terms aren't fully explained. The Supreme Court affirmed, emphasizing that when one party cannot read and mistake is alleged, the enforcing party must prove the terms were fully explained. The decision demonstrates the Civil Code's protection of disadvantaged parties in contract formation and establishes important precedent regarding consent in contracts involving illiterate parties.